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Postcards to Advertise Consumer Loans (APR)

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Question: 
If we use postcards to advertise consumer loans can the APR disclosure be on the flip side or does it have to below the APR on the same side?
Answer: 

Just to clarify - you say "APR disclosure". Including the APR is not required unless you've also included a trigger term as defined in 1026.24(d)(1). If you have, then yes, APR is one of the additional terms you must disclose, along with others specified at 1026.24(d)(2). In the case of a postcard where information is included on both the front and back, I would treat that as a multi-page advertisement under the provisions of 1026.24(e) in which case you can have the schedule of other required disclosures on a different page, as long as there is a clear reference to where that information is located. For example, I'd recommend putting a statement clearly at the bottom of the front page that says something like "See reverse for additional important information".

First published on 10/01/2017

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